On 1 January 2025, Royal Decree 1055/2022 will introduce a labelling requirement for packaging in Spain, which will present companies with new challenges. From this date, all packaging that can be categorised as household waste must be clearly labelled with recycling information. This not only affects Spanish companies, but also anyone who exports products to Spain.

But why is this change necessary? Spain has set itself targets to promote environmental protection and improve recycling rates. The labelling requirement is intended to make it easier for consumers to dispose of packaging waste correctly, which should contribute to higher recycling rates and a more efficient circular economy.

These new regulations will have a direct impact on you if you export packaged products to Spain that are generated there by private end consumers. Regardless of whether you use plastic packaging, paper packaging or glass containers – specific labelling requirements will apply to each type of packaging from 2025 and must be met. It is therefore high time to review and adapt your packaging to meet the new requirements.

The labelling obligation applies to all so-called ‘household packaging’ – i.e. packaging that typically accumulates with end consumers in private households. In Spain, the term ‘envases domésticos’ is used for this. This means that food packaging, beverage packaging as well as packaging for household goods and consumer goods are affected by the regulation.

If you export packaging to Spain or sell your products there, you must ensure that the packaging is correctly labelled. This applies not only to the outer packaging, but also to all packaging components. This includes, for example, labels, plastic sleeves or boxes that wrap the product. Even if your packaging consists of different materials, you are obliged to attach the appropriate disposal labelling for each material.

An example: Your packaging consists of a glass bottle with a plastic lid. In this case, you must affix two symbols to the packaging – one for the glass container (green container) and one for the plastic lid (yellow container). If the packaging consists of several materials that cannot be separated from each other (e.g. composite materials), you must use the symbol for the material with the largest proportion by weight.

The labelling must be clearly visible, legible and permanently affixed to the packaging. Minimum size and design requirements must also be met to ensure that the information reaches the consumer clearly and unambiguously.

In order to fulfil the new legal requirements in Spain, you must label your packaging with special symbols for waste separation. These symbols inform consumers in which containers they should dispose of their packaging waste. You can either develop a symbol yourself or use existing symbols.

In Spain, packaging waste is sorted into four main fractions, for each of which different containers are provided:

• Yellow container: Plastic and metal packaging (e.g. drinks cans, plastic bottles)
• Blue container: Paper and cardboard packaging (e.g. cardboard boxes, paper packaging)
• Brown container: Compostable packaging (e.g. biodegradable packaging, organic waste)
• Green container: Glass packaging (e.g. glass bottles, jam jars)

For each of these fractions, you must affix appropriate waste separation symbols to your packaging. If it is not possible to use the official colours for labelling (yellow, blue, brown, green) for design reasons, you can also use black and white variants. In this case, however, you must mention the relevant container in writing to avoid any misunderstandings during disposal.

The new labelling regulations in Spain not only require a symbol to be displayed, but also that it meets certain requirements. To ensure that everything is legally correct and remains clearly recognisable for consumers, there are some important requirements that you must observe:

• Minimum size and visibility: Each labelling symbol must be at least 8 mm in size. Ideally, you should use a size of 10 mm to optimise legibility. The symbols must be clearly visible on the packaging and must not be obscured by other design or packaging elements.
• Colour specifications: The official recommendation is to label in the colours yellow, blue, brown and green, according to the respective disposal fraction. If this is not possible for design reasons, you can use black and white or other colour variants.
• Special rules for composite packaging: If your packaging consists of several materials that cannot be separated from each other, indicate the material with the largest proportion by weight. This allows consumers to dispose of the packaging correctly.
• Reusable and compostable packaging: Reusable packaging, such as cans or bottles, must also bear the symbol of the deposit return system (DRS). Compostable packaging must be labelled ‘Do not discard in the environment’ and be certified in accordance with UNE EN 13432:2001 or a comparable standard.

The mandatory labelling of packaging in Spain from 2025 brings new challenges, but also opportunities for companies. With clear guidelines on waste separation and disposal, the legislation aims to improve the recycling process and raise environmental awareness among consumers.

For you, this means adapting your packaging in good time and fulfilling the legal requirements. By implementing the new rules, you not only contribute to a cleaner environment, but also strengthen your customers’ trust in your sustainability efforts.

Commercial packaging will also be subject to system participation in Spain from January 2025. While this obligation previously only applied to household packaging, commercial and industrial packaging will also be affected from next year.

So that you can prepare in good time and fulfil all the new requirements, have a look here.

The Danish parliament has approved the delegation of responsibility for packaging and single-use plastic products to companies placing them on the market, based on the polluter-pays principle. This means a significant redistribution of the costs of recycling: what was previously borne by citizens will now be transferred to manufacturers.

Companies placing packaging on the market must now bear the costs of collecting and sorting household waste and participate in programmes to reduce packaging waste and promote recycling. The EPR for packaging applies to all types of packaging, regardless of whether it is plastic, glass, wood, metal, cardboard, paper, etc. In Denmark, a distinction is also made between three types of packaging: primary and sales packaging, secondary packaging and multipacks, and tertiary and transport packaging. It is estimated that around 41,000 companies will be affected by this regulation. In addition, charges will be introduced for the disposal of single-use plastic.

There are exceptions for smaller manufacturers: Companies that put less than 8 tonnes of packaging into circulation in Denmark each year will have to provide less detailed information. This regulation will be reviewed again in 2027.

A registration obligation for packaging according to the Danish regulation (Bekendtgørelse om registrering og indberetning af emballage) in the Danish producer register existed until 31 August 2024.

On 20 September 2024, an additional regulation (Bekendtgørelse om visse krav til emballager, udvidet producentansvar for emballage samt øvrigt affald der indsamles med emballageaffald) was published. This new regulation extends the previous regulations and is expected to come into force on 31 December 2024.

According to this new regulation, there are further deadlines for companies that place packaging on the Danish market:

• All manufacturers must have joined a collective system by 14 January 2025.
• Producers must report the packaging quantities actually placed on the market in 2024 by 1 June 2025. Simplified reporting is available for manufacturers who place less than 8 tonnes of packaging on the Danish market per year.

You are obliged to register your company with Dansk Producent Ansvar DPA and report your packaging volumes for 2024. In addition, you must have participated in a collective system by 31 August 2024 and appoint an authorised representative. Missed this important deadline? Don’t worry! We can help with our licensing service!

This policy decision aims to identify those in the value chain who have the greatest influence on packaging design. It is an important step towards improving waste management and recycling in Denmark and strengthening the circular economy.

In order to reduce the impact of packaging and products on the environment, Finland has adapted its EPR (Extended Producer Responsibility) regulations. Registration with a collective system has been mandatory in Finland since 2024, whether for big players or newcomers. By removing the exemption limit for companies with a turnover of less than one million euros, Finland is taking a major step towards protecting the environment and resources. The adjustment in the Finnish definition of a producer is entirely in line with EU regulations.  

This means that all companies in Finland, regardless of their turnover or size, must now fulfil their extended producer responsibility for their packaging.  

There are also changes in the area of service and agricultural packaging. Producers or importers of service packaging, such as pizza boxes or coffee-to-go cups and agricultural packaging intended for agricultural products, now also fall under the definition of producer in the Finnish Packaging Act. Since then, the producer is responsible for the packaging, not the companies that actually fill the packaging and hand it out to customers. The regulation relieves the burden on small shops and restaurants. 

If you are a foreign company packaging products for the Finnish market or importing packaged products and have a permanent location or branch in Finland or sell packaged products from abroad to Finnish end customers, you are responsible for fulfilling your Finnish EPR obligations.  

Your obligations include registering with a collective system such as Rinki (where you pay a one-off registration fee and annual customer fees) and preparing an annual report on the quantities of your own packaging waste for the Finnish authorities. You also pay annual recycling fees depending on your packaging volumes. If you do not register with a collective system, you are free to set up your own system for collecting, sorting and recycling your packaging, but this involves a lot of bureaucracy.

Saving fees with recyclable packaging? It’s possible! To encourage companies to use recyclable packaging, Finland, like some other EU countries, is implementing eco-modulation.  

This means that you can reduce your recycling fees for packaging based on its recyclability. Fees for packaging made of mono-material, i.e. packaging made of only one type of plastic, are therefore lower than for packaging made of different types of plastic.   

Finland has been implementing this regulation since 2023. At the beginning of 2024, the regulation was expanded to include categories for metal and paper.

With the extension of the EPR obligations in the packaging sector by removing the turnover limit, almost 30,000 companies in Finland will be made more responsible. Costs will be distributed more fairly and recycling will be more effective. Although this increases the administrative burden for some companies, the extension represents an opportunity for the circular economy and thus for environmental and resource protection.

Eco-Fee Modulation is an instrument to promote the European circular economy. It is intended to incentivise companies to increase the use of recyclable packaging. Some EU countries are already using it to differentiate the licence or recycling costs in their respective EPR systems.  

Specifically, modulation aims to incentivise the development of sustainable packaging designs by differentiating the licence fees for sales packaging. In short, companies that use environmentally friendly packaging pay lower licence fees to the EPR systems and thus save costs. On the other hand, packaging that does not fulfil the requirements of eco-modulation is taxed more heavily and is therefore more expensive. This approach is an important step towards an environmentally conscious economic policy that promotes ecological sustainability. 

In the European Union, the Packaging Directive requires companies that put packaging into circulation to ensure its disposal. This principle is known as extended producer responsibility (EPR). However, the specific requirements and obligations vary from country to country, as each country has developed its own laws to implement the EU directive. However, the basic principle remains the same everywhere: companies that put packaging into circulation pay a licence fee to an EPR system that is responsible for the collection, sorting and recycling of packaging waste.

In Germany, for example, companies fulfil their obligations by registering and reporting data in the LUCID packaging register and licensing their packaging with a dual system such as Interseroh+ via Lizenzero. Do you ship to the EU? With our licensing service, we can easily fulfil all your obligations per country for you! 

The standardisation of the eco-fee at European level is a desired goal, but implementation currently varies greatly from country to country. While certain materials are already taxed in some countries, others have not yet introduced eco-fees. Incentive models in the form of eco-fee modulation have already been introduced in France, the Netherlands, Belgium and Finland. However, the exact structure varies from country to country.   

In principle, however, the recyclability of packaging, on which the eco-fee is based, is orientated towards the following criteria:  

• Sortability and separability  
• Source material (paper, plastic, metal, glass)  
• Residual emptiability
• Contaminants in the material 

Do you ship to different EU countries? We take care of your packaging licensing! On top of that, we can also check for you whether the design of your packaging meets the requirements of Eco-Fee modulation in your target markets. If the design of the packaging does not yet meet the Eco-Fee requirements, we can also support you in adapting your packaging to the standards on request.